A.C. No. 3944 - Payod vs. Metila

Lea P. Payod, the petitioner, brought an action charging Atty. Romeo P. Metila, the respondent, with willful neglect and gross misconduct.
The charges stemmed from the respondent’s handling of Payod’s previous petition (G.R. No. 102764) for review which was dismissed for failure to comply with the requirements set forth in Revised Circular 1-88.
The dismissal was based on the petitioner’s failure to timely file and submit the necessary documentation, as mandated by the Court.

Petitioner contends that it is inconceivable for practicing lawyers to omit important documents unless dictated by gross negligence or willful misconduct.
She alleges that, along with her family members, she encountered repeated difficulties in obtaining the promised actions from the respondent, who gave unreasonable excuses and consistently failed to attend scheduled meetings at the Supreme Court.
Petitioner emphasizes that her constant follow-ups, payments of fees, and readiness to provide supporting materials were met with non-performance by the respondent.

Atty. Metila states that the case was referred to him on November 29, 1991—just six days before the deadline for filing an appeal—with incomplete records except for the Court of Appeals resolution denying the motion for reconsideration.
He claimed to have advised Lea’s mother to secure another lawyer for obtaining the complete certified records and managing the petition for review, insisting that no valid attorney-client relationship existed due to the absence of a Special Power of Attorney.
Despite the communication gap until January 21, 1992, the respondent proceeded to finance and undertake the expenses for initiating the appeal.

The IBP Committee on Bar Discipline investigated the complaint and determined the respondent was guilty of simple negligence.
They recommended that he be seriously admonished and subjected to three units of Mandatory Continuing Legal Education in Remedial Law for his failure to keep current with legal developments and his cavalier denial of an attorney-client relationship.
The IBP Board of Directors subsequently adopted the report and recommendation.

The Court noted that while the respondent did fail to meet certain procedural requirements in initiating the appeal, his actions did not rise to the level of gross negligence or show a blatant absence of real effort.
It was acknowledged that the respondent, given the constraints of receiving the case mere days before the deadline and with incomplete documentation, still made efforts by filing two motions for extension of time and ultimately submitting the petition within the extended period.
The Court emphasized that his conduct fell short of the high standard required in the practice of law—specifically, keeping abreast of legal developments and serving the client with competence and diligence.

Whether Atty. Romeo P. Metila’s conduct in handling Payod’s case constituted willful neglect and gross misconduct as charged.
Whether the non-existence of a Special Power of Attorney, which allegedly negated an attorney-client relationship, exempts the respondent from liability.
Whether the procedural constraints—limited time and incomplete documentation—justify the respondent’s delayed and inadequate performance.
What appropriate disciplinary measures should be imposed in view of the respondent’s failure to comply with professional standards.